Privacy Policy

Introduction

Moneycorp Group (“Moneycorp” “we”, “our”, “us”) is committed to ensuring that your personal data is used correctly and in accordance with the highest standards of Data Protection Law.

This Privacy Policy (“Policy”) explains in detail the types of personal data we may collect about you and what we do with your personal data. It also set outs what we do to keep your personal data secure, as well as your rights in relation to the personal data we hold about you.

Copies of documents you provide to prove your age or identity. For example, your passport, driving licence, marriage certificate and utility bill.

Copies of documents you provide to prove your source of funds. For example, your bank statement or payslip.

Bank account and payment card details

Information we collect about you when you use our Services or contact our team:

Details of the transactions you carry out when using our Services, including geographic location from which the transaction originates.

If you have a Moneycorp online account, we will collect and keep encrypted records of your username, password and security question answers.

In relation to our websites, we will log your Internet protocol (IP) address so that it recognised next time you visit.

CCTV Images at our bureaux de change.

We will update the information we hold on you as and when you provide it to us during our communications with you. However, whenever possible, you should advise us if information we hold on you needs updating or is no longer accurate.

When you visit any of our websites or download and install the Moneycorp app.

When you make an enquiry about our Services or open an account with us online, over the telephone, by post or in person. When you make international payments online, over the telephone, by post or in person.

When you reserve or purchase foreign currency with us online or in person at one of our bureaux de change.

When you enter into a competition or take up a promotional offer.

When you have given a third party permission (e.g. a Referring Partner) to share with us your personal data.

When you report a problem, make a query or issue a complaint about our Services.

When you visit a Moneycorp travel money bureaux de change, you may be recorded on CCTV.

During correspondence with Moneycorp employees (or persons acting on our behalf) over telephone, email, post or in person. Telephone calls made and received by Moneycorp may be recorded and internally monitored for the purposes of 1) ensuring that Moneycorp complies with its regulatory obligations 2) evidencing your use of our Services 3) investigating complaints 4) gathering evidence in disputes and 5) improving Moneycorp’s Services (training and quality control). Moneycorp may also maintain a record of all emails sent by or to Moneycorp for the same purposes.

Data Protection Law sets out six lawful basis that organisations, businesses and governments can rely on to collect and process personal data. Moneycorp predominately relies on the following:

Consent

This means processing your personal data where you have explicitly given us permission to do so.

Performance of a Contract

This means processing your personal data in order to fulfil our contractual obligations with you.

Legal Obligations

This means processing your personal data where it is necessary for compliance with a legal or regulatory obligation to which we are subject.

Legitimate Interests

This means processing your personal data where we or a third party have a legitimate interest to do so. We make sure we consider and balance any potential impact on your rights before we process your personal data for our legitimate interests. Where our interests are overridden by a negative impact on your rights, we will not process your personal data.

We may process your personal data for the following purposes, depending on how you interact with us.

1. To complete the delivery of our foreign exchange, bank and international payment services (“Services”)

Without your personal data, we would not be able to open your moneycorp account, facilitate your foreign exchange transactions and complete the delivery of our services.

As part of our online account opening process, we will send you a one-off follow up registration email should you not complete the second page of the online account registration page. We will do this on the basis of our legitimate interests.

2. To respond to your queries and complaints

Without your personal data, we would not be able to effectively respond and handle queries or complaints. We may keep a record of our correspondence to demonstrate how we communicated with you throughout. We will do this on the basis of our legitimate interests and our legal obligations.

3. To comply with our legal and regulatory obligations

In order to meet our legal and regulatory requirements, we are required to carry out regulatory checks in order to prevent and detect fraud, money laundering, identity theft and other crimes. We are also required to send you communications known as ‘service messages’ in order to inform you about changes to the services we provide you. For example, changes to our terms and conditions and privacy policy, reserve and collect order confirmations and proof of payment confirmations. These service messages will not include any promotional content and cannot be unsubscribed from.

4. To analyse, test and improve our systems and databases

We may use your personal data to ensure that our systems are tested thoroughly. This ensures that the system can cope with comparable volumes of information, that a wide range of realistic scenarios are covered, and that the test will reflect all the possible combinations that occur in the real environment. Test systems are isolated from external networks to ensure that live systems are not compromised. In addition, to ensure data is not compromised, we carry out various risk assessments, and have implemented safeguards to ensure data security. We will do this on the basis of our legitimate interests.

5. To develop new and improved products and services, including conducting market research and product analysis

For this purpose, we will use cookies to personalise your next visits to our websites and to measure volumes and patterns of website usage. Full information can be found in our Cookie Policy here. This includes information on how to adjust your browser settings to accept or reject cookies. We will do this on the basis of our legitimate interests.

6. For training and quality purposes

We are continually reviewing the quality of the services we provide in order to improve your experience with Moneycorp. We will do this on the basis of our legitimate interests.

7. To keep you informed about relevant products, special offers and market news

For existing customers who currently agree to receive marketing, we will continue to send you relevant products, special offers and market news unless you tell us otherwise. We will rely on our legitimate interests and the soft opt-in exception made available by the Privacy and Electronic Communications Directive 2002 to do this.

For new customers, we will only keep you informed about relevant products, special offers and market news where you have explicitly consented

You are free to opt out of receiving marketing communications from us at any time by one of the options set out in the “Managing your marketing preferences” section of this Statement.

Companies that carry out our direct marketing and research survey email and text campaigns on our behalf.

3) Public authorities

This will only be in response to lawful requests made from public authorities in order to meet national security, public interest or law enforcement requirements.

4) Other third parties

With your consent only, we may pass your data to a third party for their direct marketing purposes.

In the event we sell divisions of our business, we may disclose your personal data to prospective purchasers and their advisers so they can evaluate the relevant business.

If you have been referred to Moneycorp by a third party who you have a direct relationship with (e.g. an estate agent or an Independent Financial Advisor), we may provide such third party with personal data relating to you in which they are interested in by virtue of Moneycorp’s agreement with them and where your interests and data protection rights do not override those interests.

If you are a Sainsbury’s International Money Transfer customer, we will pass your name and contact details to Sainsbury’s Bank plc so they can remove you from marketing intended for individuals who are not yet Sainsbury’s International Money Transfer customers.

If you have a Moneycorp explorer card, we may share your personal data with the card programme manager, Mastercard Payment Management Services Limited, and the card issuer, Wirecard Card Solutions Limited, in order to provide the explorer card services.

Please note our websites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for them. Please check these policies before you submit any personal data to these websites.

Sharing your personal data outside the European Economic Area

The personal data that we collect from you may be transferred to, and stored at, destinations both in and outside the European Economic Area (“EEA”).

Where processed outside the EEA, we will take appropriate steps to ensure your personal data still receives a level of protection that is consistent with European data protection standards. For example, we will only share your personal data outside the EEA if we have an EU approved model clauses agreement in place or if the third party receiving your personal data has signed up to an EU approved data sharing mechanism such as the EU-US Privacy Shield scheme.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

Personal data is protected by a defence in depth security programme that is aligned to best practice found in International Organisation for Standardisation (ISO 20071) and National Institute of Standards Technology (NIST) documentation. Protections include, but are not limited to, mature access control (with strict procedures around privileged access), network segmentation, standard security appliances (firewalls, IPS, AV, monitoring via SIEM), secure configuration and system hardening, monthly vulnerability assessments and yearly penetration tests, documented processes and procedures, DLP protection, rogue detection, and monthly rolling patch management and vulnerability remediation. Payment card information is tokenized to ensure it is protected. We also secure access to all transactional areas of our websites and apps using ‘https’.

We provide our employees with training and detailed information about our data handling practices through internal company policies such as our Data Protection Policy. All employees have to certify that they have read and understood the contents of our Data Protection Policy where is reviewed and updated on an annual basis. As well as our data protection policy, which governs how we process data throughout the Moneycorp Group, we have a separate suite of internal policies which govern areas such as information security and information classification.

Whenever we collect or process your personal data, we will only keep it for the purpose for which it was collected and in accordance with our legal and regulatory obligations. In most cases, our retention period for your personal data will come to an end six years after the end of your relationship with us.

Inactivate Accounts

If you have not used your account for more than two years, it will be flagged as inactive and we’ll contact you to ask whether you want to keep it open. Unless you reply to say ‘yes’, we will close and deactivate your account.

Closed Accounts

If you inform us you longer wish to have a Moneycorp account, we will close and deactivate your account.

At the end of the retention period, your personal data will either be anonymised (so that it can only be used in a non-identifiable way for statistical analysis, business planning), made inaccessible or unintelligible (for system integrity purposes) or deleted completely.

You have a number of rights under Data Protection Law which, in certain circumstances, you may be able to exercise in relation to the personal data we process about you. This includes:

Right to Access: You have a right to receive a copy of the personal data we hold about you. This is commonly known as a Data Subject Access Request.

Right to Data Portability: You have a right to receive certain information you have provided to us in a ‘machine-readable’ format and/or request that we transmit it to a third party.

Right to Erasure: You have a right to request that we erase your personal data. However, we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Right to Object: In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Right to Lodge a Complaint: You have the right to lodge a complaint with your national data protection authority. Further details can be found in the "Contact" section of this Policy.

Right to Rectification: Where your personal data is inaccurate, out-of-date or incomplete, you have the right to request an amendment to it.

Right to Withdraw Consent: Where you have given us your consent to process your personal data, you have the right to change your mind at any time and withdraw that consent.

If you wish to exercise any of these rights, please get in touch by using the details in the “Contact” section below. Please note we will ask you to verify your identity before proceeding with any request you make.

There are a number of ways you can update or stop direct marketing communications from us:

Click the ‘unsubscribe’ link in marketing email communication that we send you. We will then stop any further emails from that particular business entity of Moneycorp. Please note that unsubscribe links are not included in service emails because you cannot unsubscribe from service emails.

If you have a Moneycorp Bank or International Payments account, login into your account, visit the ‘My Account” section of the homepage and click on the “Manage my Communications” link.

If you are a Moneycorp US Inc. customer, your personal data will processed be in accordance with the terms of this Policy and applicable U.S federal and state law. For the purposes of this Policy, references to ‘personal data’ includes ‘non-public personal information’ as defined in The Gramm-Leach-Bliley-Act.

As part of the Moneycorp Group, please note your personal data may be processed by other Group entities and third party service providers located outside the United States.

If you feel that your personal data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113 or visiting www.ico.org.uk.

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection authority in your country of residence.

For other matters, please contact your Account Executive or your usual point of contact. You can also speak to a member of our team by calling Customer Services here.

We reserve the right to amend this Policy from time to time without notice in order to be consistent with Data Protection Law requirements. Where we do make significant changes to this Policy, we will take appropriate steps to bring those changes to your attention.

This means the EU General Data Protection Regulation 2016/679 (GDPR) and European Member’s States national implementing legislations; the e-Privacy Directive 2002/58/EC (as amended by Directive 2008/136/EC) and European Member’s States national implementing legislations; US Federal Law (including, but not limited to The Federal Trade Commission Act, The Gramm-Leach-Bliley-Act of 1999 (GLBA), The CAN-SPAM Act 2003 and the Telephone Consumer Protection Act) (applicable to Moneycorp Inc and Moneycorp US Inc. only); US State Law (including, but not limited to The California Electronic Communications Privacy Act, The Standards for The Protection of Personal Information of Residents of the Commonwealth and The Florida Information Protection Act (applicable to Moneycorp Inc and Moneycorp US Inc. only); The Australian Privacy Act 1988 (applicable to TTT Moneycorp PTY Limited only); The Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (Ordinance) (PCDP) (applicable to Moneycorp (Hong Kong) Limited only); The Data Protection Law (DIFC Law No. 1 of 2007) (UAE representative office only); and The Internet Bill of Rights Law (Marco Civil da Internet) and The Consumer Protection Code (Código de Defesa do Consumidor) (applicable to Novo Mundo Corretora de Câmbio only).

European Economic Area

The means the countries of the European Union and members countries of the European Trade Association. A complete list of applicable countries can be found at: https://www.gov.uk/eu-eea

This means information that can be used to directly or indirectly identify a living person.

Process, Processing, Processed

This means operation or set of operations which are performed on data. This includes collecting, viewing, recording, organising, structuring, storing, using and destroying.

Referring Partner

This means an entity who has referred an individual or company to a Moneycorp Group establishment in order to engage in our services. They are also known as Introducers and include property agents, law firms, financial accountants and banks.

Services

This means our foreign exchange, international payment and bank products and services provided by Moneycorp Group companies.

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